Petition for Exemption 14 CFR § "11.81 

Exemption petition under SEC 331 

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*Your name and mailing address. You may include 

other contact information such as a fax 

number, ,telephone number, or email address; 

Name: Bruce Kist 

Address:. 44 Hami 1 ton Dr. Spotswood, NJ 08884 

Phone: 732 261 0234 

Email :.,:Brl,lcieiam@aol.com 

*The specific section or sec~ions of 14 CFR from 

which you seek an exempt:i'on; 

Petition for Exemptidn under s~c 3j3 · .· 

*The extent of relief you seek and the reason you seek the relief;· 

sec 333 prohibits the use bf a UAS for .commercial purposes on private property. I am a 

professional photographer of 45 years and am simply petitioning for an 

exemption to 

provide a commercial service to private land owners and companies who wish to obtain and · capture Aerial photos and videos of said property for purposes including real estate listings, insurance property claims, and for use as a marketing tool for 

businesses. I would like to be able 

to accept payment for these services therefore making this a 

commercial use of a UAS. 

*How your request would benefit the public as a 

whole; 

My request benefits the public as a whole by providing an opportunity for small business 

owners, real estate agents, and others who wish to document their land 

or property to take 

advantage of the technology that now exists in the form of UAS's and 
allows them to do so safely by using this newest technology. 

*Reasons why the exemption would not adversely affect 

safety, or how the exemption would 

provide a level of safety at least equal to the 

existing rule; 

Being a pilot in training and a AMA R/C pilot in training, I therefore 

understanding the 

importance of different uses and safety concerns regarding FAA 

regulated airspace, I would be 

a good candidate for exemption of sec 333 while not putting Air safety in any accelerated risk. 

The specific UAS I will be using is state of the art with GPS 

guidance, SAFE technology and designed with 

safety first features. when flying for this commercial purpose I would 

be flying at a maximum altitude of 

125 feet and flying mostly vertically for the purposes of taking photos, decreasing the risk of 

any interference. My general knowledge of the aviation safety systems implemented by the 

FAA would be used to ensure that safety would not be affected by my operations. I would not 

be flying near disaster areas, sporting events, or high traffic areas 

including airports, and I 

would pay attention to NOTAMS. 

I have enclosed information about the unit I will be 

flying. 

I Intend to follow these suggested safety regulations 

• Always keep aircraft in sight and under control: 

• Always keep people and pets at least 35 feet (10 meters) away when 

the 

battery is connected. 

• Keep children out of the vicinity of this product at all times. 

• Always use fully charged batteries. 

• Always keep transmitter powered on while aircraft is powered. 

• Always remove batteries before disassembly. 
• Always keep mov1ng parts clean. 

• Always keep parts dry. 

• Always let parts cool after use before touching. 

• Always remove batteries after use. 

• Always have a first aid kit with you. 

• Always have an appropriate fire extinguisher with you. 

• Never operate aircraft with damaged wiring. 

• Never touch moving parts. 

*A summary we can publish in the Federal 

Register Federal Register -

I, Bruce Kist, am seeking an exemption of the FAA's sec 333 rules that 

does not allow the use of 

an Unmanned Aircraft to be used for commercial purposes in regards to 

National Airspace safety. I am simply petitioning for an exemption to provide a 

commercial service to private land 

owners and companies who wish to obtain and capture Aerial photos and videos of said · · property for purposes including real estate listings, insurance 

property claims, and for use as a 

marketing tool for businesse~. Being ~ private pilot in training and a 

AMA R/C pilot in training, I 

therefore understanding the importance of different uses and safety 

concerns regarding FAA 

regulated a1rspace, I would be a good candidate for exemption of sec 

333 while not putting Air · safety in any accelerated risk. The specific UAS I am seeking exemption with is one with many safety programs, including SAFE technology and GPS navigating. when flying for this 

commercial purpose I would 

be flying at a maximum altitude of 125 feet and flying mostly vertically for the purposes of 

taking photos, decreasing the risk of any interference. My general knowledge of the aviation 

safety systems implemented by the FAA would be used to ensure that 

safety would not be 

affected by my operations. I would not be flying near disaster areas, sporting events, or high traffic areas including airports, and I would pay attention to NOTAMS. 

I appreciate the FAA's · · consideration of this petition for exemption. 
*Any additional information, v1ews, or arguments available to support your request; 

I am fully aware of the pre flight safety checks and procedures and 

intend to implement pre flight safety checks and utilize the safety technology provided with th1s unit. I intend to only fly in non 

populated, residential or 

rural areas and stay clear of all utility lines etc. I intend to be fully aware of my surroundings at 

all times and to only fly the unmanned aircraft within a visual line of sight and only in Visual 

Flight conditions. 

I have enclosed information about the unit I will be flying. 

I understand and will comply with all the health and safety regulations for PIC's and will be 

the only operator under this exemption. 

General safety Precautions and warnings I int~nd to Follow 

• Always keep a safe distance in all directions around your model to avoid collisions · · · 

or injury. This model is controll.ed b~ a radio signal subject to 

interference 

from many sources outside your control. Interference can cause 

momentary 

loss of control. 

• Always operate your model 1n open spaces away from full-size 

vehicles, traffi c 

and people. 

• Always carefully follow the directions and warnings for this and any optional 

support equipment (chargers, rechargeable battery packs, etc.). 
" ' 

• Always keep all chemicals, small parts and anything electrical out 

of the reach 

of children. 

• Always avoid water exposure to all equipment not specifi cally designed and 

protected for this purpose. Moisture causes damage to electronics. 

• Never place any portion of the model in your mouth as it could cause 

serious 

injury or even death. 

• Never operate your model with low transmitter batteries. 

• Always keep aircraft in sight and under control. 

• Always move the throttle fully down at rotor strike. 

• Always use fully charged batteries. 

• Always keep transmitter powered on while aircraft 1s powered. 

• Always remove batteries before disassembly 

• Always keep moving parts clean. 

• Always keep parts dry. 

• Always let parts cool after use before touching. 

• Always remove batteries after use. 

• Never operate aircraft with damaged wiring. 

• Never touch moving parts. 

*If you want to exercise the privileges of 

your exemption outside the united States, you must 

state the reason. 

I have no intention on using this exemption outside the united States 
a,t1C/2G15 DJI Phantom3Adwnced Quadcopter wth 1080p Camera and 3-Axis Gimbal 

~.: .... ~·.f..}........................................................................................................................................................................................................................................................ ........................... ......................... .. !A complete 1080p camera and 3-axis gimbal system come integrated with the Phantom 3 Advanced edition quadcopter 

\fromDJI. In addition to video, the camera is capable shooting up to 12MP still photos using JPEG or non-proprietary DNG RAW 

[format. The three axes of the gimbal give you pan and tilt control, and keep the horizon line level even as the aircraft banks. 

!Different gimbal settings allow the camera to lock onto a fixed subject, be moved manually using transmitter rotaries or the 

ja pp, or to simply provide camera stabilization. 

~his bundle of the Phantom 3 is classed as "ready-to-fly." This means the basics to get you in the air are included -a flight 

!battery, charger, and pre-bound handheld transmitter (radio controller) among them. Depending on you application, you may 

!also require a microSD memory card for in-camera recording, additional flight batteries, and a mobile device to access the app, 

!and possibly other accessories. Also note that a number of important compass and GPS calibration steps must be carried out 

!before flying to ensure the flight control computer operates correctly. Please refer to the manual or Quick Start Guide before 

jyour first flight. 

~Phantom 3 Flight Control System 

!Main Controller 

\The burden of processing and analyzing flight data in real time it taken up by the Main Controller, the brains of the 

!computerized flight control system. It collects data from the entire system, including motor speed, GPS location, your command 

[inputs, and data from automatic sensors, and analyzes it all to tell your Phantom 3 exactly how to behave at any given 

[moment 

',GPS Navigation 

jBecause of the complexity associated with multi-rotor aircraft the Phantom 3 relies on a GPS-based navigation system to 

!maintain flight stability and provide other features. While fully manual operation is possible, most users, especially 

ivideographers hoping to get the smoothest possible shoots, will opt for one of the GPS-assisted modes 

liMU 

~he Inertial Measurement Unit (IMU) uses a 6-axis gyroscope plus an accelerometer to keep track the slightest tilt or change 

[in acceleration. This data is relayed to the Main Controller and used to help maintain a stable flight ! 

iESCs 

[Four Electronic Speed Controllers (ESCs) not only relay vital motor speed information to the Main Controller, they also send 

[commands back to the motors based on your input. This constant communication helps keeps your Phantom 3 stable in flight, 

'and also helps you achieve any flight movement, from gentle pans to rapid acceleration 

Vision Positioning System for Indoor Navigation 

:Vision Positioning System uses a specially designed camera as well as sonic waves to provide comparable stability function 

!indoors or dose to the ground as GPS does outdoors. This technology allows the Phantom 3 to hold its location, stop when 

lthe controls are released, and quickly respond to pilot commands even when GPS is unavailable 

Auto-Takeoff 

[With one tap in the DJI Pilot app, the Phantom 3 will turn on its motors and raise to a pre-set height. It will then hover in 

[place, completely motionless until you direct it where to go 

jAuto-Landing 

!when GPS is available, the Phantom 3 remembers the exact spot that it took off. Simply tap a button to have it return to the 

!poinf from which it took off 

!Return to Home Failsafe 

lrf the Quadcopter loses the signal from the controller for any reason or the battery starts to run low the "return to home" 

!feature will initialize. The aircraft will ascend to 60 feet then make a straight-line course back to the "home position" you will 

,have defined during the GPS calibration process. Once there, it will safely descend to the ground and power itself off 

; 

!Intelligent Orientation Control (IOC) 

lroc is designed to help make flying more intuitive. Nominally, the yaw control will allow the Quadcopter to rotate continuouslyj 

[which can quickly become confusing if you lose track of which way is "front". Suddenly your controls can get mixed up, where 

[pressing right causes the craft to move left and pressing forward causes it move backward. Intelligent Orientation Control 

jprevents this from happening, keeping the "tail" of the Quadcopter pointed roughly toward the pilot at all times 

!On-Board 1080p60 Camera 

jup to 1080p60 Video and liMP Stills 

The included camera system features video recording at up to 1080p60 in H.264 and also takes JPEG and DNG RAW photos at 

!12MP. The camera mounts via an integrated 3-axis gimbal that provides stabilization as well as pan and tilt control. Media is 

'recorded internally to a microSD card 

Video Resolutions and Frame Rates 

j1080p (1920 x 1080): 24p, 2Sp, 30p, 48p, SOp, 60p 

j720p (1280 x 720): 24p, 25p, 30p, 48p, SOp, 60p 

194° Wide Angle Lens 

The camera features a 94° angle-of-view lens, which is a narrower angle than a fisheye for less distortion while still being 

!wide enough to enable capturing establishing shots. The lens features an f/2.8 aperture and is comprised of 9 elements, 

!including an aspherical element 

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8/1Clf2G15 DJI Phantom 3 Advanced Quadcopter wth 1 080p Camera and 3-AJQs Gimbal l 

Int\~grate..:J 3-Axis Gimbal 

~he gimbal provides stability by counteracting unwanted motion such as wind buffeting or vibration and also keeps the 

!horizon level even as the quadcopter banks. Control dials on the transmitter (radio controller) allow you to manually pan and 

\tilt the camera 

!oJI Pilot App for Android and iOS 

!Camera Control and Monitoring 

!View a live image with the free Pilot mobile for Android or iOS mobile device. The app also enables full camera control, letting 

!you set parameters such as camera tilt, ISO, shutter speed, white balance as well as set video start/stop and take photos. 

The mobile device tethers to the transmitter via USB (cable available separately) 

;In-App Editing and Upload 

!once recorded, photos and video footage can be downloaded directly to the phone allowing them to be edited complete 

!with music, text, and more, and shared on Face book, lnstagram, or other social media networks- even while the Quadcopter 

jis still in the air. If you have an Internet connection, you can even stream live to YouTube 

!Flight Simulator 

' 

~he a pp isn't just for flying. A flight simulator allows you to get some practice in before taking to the skies. A flight log allows 

:you to review all of your past flights, with the time, duration, and even photos and videos you took 

;Handheld Transmitter (Radio Controller) Included 

~ntuitive Design 

' 

'with sensitive control sticks, dedicated buttons, and over 1.2 mile range, the customizable Phantom 3 remote controller has 

!been designed to put the controls you need where you need them. Functionality includes: 

!Power on/off 

h'a ke photos 

!Start/stop recording video 

!Gimbal control dial 

!Camera settings dial 

!Sensitive control sticks 

:Flight mode switch 

!Return Home button 

!USB output 

\Customizable buttons 

\Mobile device holder 

!Power indicators 

islip-free rubber matte 

jMobile Device-Compatible 

,A type A female USB connector is provided for tethering an iOS or Android smartphone or tablet for live FPV monitoring and 

jcamera operation. A mobile device holder is included for mounting your device directly to the transmitter. It adjusts to 

!accommodate both smartphones and tablets in landscape orientation 

'Rechargeable Battery 

A 6000mAh LiPo battery is provided to power the transmitter. An AC charger is included for charging the battery while in the 

transmitter. Four LEOs on the front of the transmitter indicate remaining battery life or charge status 

Additional Features 

Intelligent Flight Battery 

The flight battery slots into the "tail" of the Phantom 3 and features and on/off switch plus four LED charge indicators that are 

!visible while flying- so you can keep track of remaining flight time without needing to consult the app. For recharging, balance 

iand power regulation is handled internally within the battery itself. You simply plug it into a wall outlet with the supplied 

:power cord and you are good to go 

!self-Tightening Rotors 

:computational fluid dynamics (CFD) have been applied to the prop design, providing them with increased thrust and better 

!efficiency compared to previous props used on earlier Phantom models. The self-tightening design helps ensure they do not 

jloosen in flight and not require a separate prop nut 

\Maximum Speed 

Performance 

Ascent: 16.4' fps I 5 m/s 

Descent: 9.8' I 3 m 

!Hover Accuracy Vertical: ±3.9" I 10 em 

: Horizontal: ±3.3' I 1 m 

!Maximum Altitude Above Sea Level: 19,685' I 6000 m 

!Flight Time 23 minutes (depending on conditions) 

Flight Control System 

lGPS Mode GPS / GLONASS 

iVision Positioning Frequency: 50 Hz 

· Velocity Range: Below 26.2 fps I 8 m/s (6.6' I 2m above the ground) 

Altitude Range: 11.8" to 118.1" I 30 em to 300 em 

Operating Range: 11.8" to 118.1" I 30 em to 300 em 

Operating Environment: Surface with clear pattern and adequate lighting (> 15 lux) 

Transmitter 

!Frequency 2.400 to 2.483 GHz 

!communication Distance 6561.7' I 2000 m (outdoors and unobstructed) 

!Receiver Sensitivity 1%PER: 101 dBm ±2 dBm 

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8/10/2(.),15 DJI Phantom 3Advanced Quadcopter wth 1080p Camera and 3-Al<is Gimbal 

EIRP: 20 dBm 

1.2Aat7.4V 

)Tta(nsmitter Power 

\Working Current 

:Connectivity 1 x USB type A female for mobile device interface 

IMobile Device Holder 

!operating Temperature 

1 x Micro-USB female for firmware updates I assistant software 1 x Charge port 

Compatibility: Tablet or smartphone 

32 to 104°F 1 o to 40°C 

Camera 

Make: Sony EXMOR 

Size: 112.3" 

\Lens 

Resolution: 12.76 MP (12.4 MP effective) 

Aperture: fl2.8 

FOV: 94° 

Focal Length: 20 mm (35 mm equivalent) 

Elements: 9 

!Photo Resolution 

:rso Range 

Focus: 0 to oo 

Up to 12 MP (4000 x 3000) 

Video: 100 to 3200 

Photo: 100 to 1600 

!Video Resolutions 

tPhoto Modes 

1080p (1920 x 1080): 24p, 25p, 30p, 48p, SOp, 60p 

720p (1280 x 720): 24p, 25p, 30p, 48p, SOp, 60p 

Single Shot 

Burst Shooting: 31517 shots 

r 

'File Formats 

Auto Exposure Bracketing (AEB): 315 

Bracketed Frames at 0.7 EV Bias 

Time-lapse 

Video: MPEG-4 AVCIH.264 in MOV wrapper (up to 60 Mbps) 

Photo: JPEG, DNG RAW 

jRecording Media Type: microSDISDXC card up to 64GB 

Format: FAT32 I exFAT 

I Note: Class 10, UHS-1 or faster card required 

.operating Temperature 32 to 104°F 10 to 40°C 

· Gimbal 

\Number of Axes 3-axis (pitch, roll, yaw) 

\Control Range -90° to +30° 

1 Motor 

>Recommended Takeoff Weight 10.6 oz I 300 g per axis 

\Maximum Tension 1.8 lb I 800 g per axis 

!stator Size 0.9 x 0.5'' 1 23 x 12 mm 

!Motor Velocity Constant KV: 960 rpmN 

iworking Temperature 23 to 104°F 1-5 to 40°C 

\Weight 1.9 oz I 55 g 

!Chemistry 

>capacity 

Flight Battery 

Lith iu m-po lymer 

4480 mAh 

68 Wh 

:configuration 45 

\Voltage 15.2 VDC 

!weight 12.9 oz 1 365 g 

!Maximum Charging Power100 W 

'operating Temperature 32 to 104°F I 0 to 40°C 

>charger Voltage: 17.4 VDC 

57W 

>Name DJI Pilot 

jsystem OS: iOS 8.0 or later; Android 4.1.2 or later 

t Requirements 

Recommended Devices: 

MobileApp 

iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air (Wi-Fi and cellular versions), iPad mini 2 (Wi-Fi and cellular 

versions), iPad Air 2 (Wi-Fi and cellular versions), iPad mini 3 (Wi-Fi and cellular versions) 

(Note: Optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus) 

Android: Samsung 55, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini 

Note: Additional devices may be compatible but have not yet been tested 

I operating Temperature 32 to 10:~'f~~\o 40°C 

\Dimensions Diagonal (Including Propellers): 23.2" 1 590 mm 

:weight Including Battery and Propellers: 2.8 lb I 1.3 kg 

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